The Federal Reserve and its fellow banking regulators published resolution plan feedback letters for 15 banking organizations, the central bank announced Tuesday, releasing the written verdicts that tell each institution what examiners want corrected in its plan for being wound down without a taxpayer bailout.
A resolution plan — often called a "living will" — is the document a large bank files to show how it could be dismantled in bankruptcy, without a federal rescue, if it failed. Regulators review the plans, then send the firm a letter spelling out the weaknesses they found and the fixes they expect. Tuesday's release covers 15 of those letters.
The Fed did not disclose which 15 organizations are covered, what specific shortcomings the letters identify, or whether any firm's plan was judged deficient. Those details come from the individual letters themselves, and the Federal Reserve's own announcement runs to a single line: that the feedback letters for 15 banking organizations were published.
A PROCESS THAT HAS BEEN TIGHTENING FOR YEARS
Resolution planning sits at the center of the post-2008 framework designed to end "too big to fail." The requirement traces to the Dodd-Frank Act, which forces large bank holding companies and foreign banking organizations with major U.S. operations to file plans and gives regulators the power to reject them.
The mechanics matter, because they determine which firms face deeper scrutiny. Under Regulation YY (12 CFR part 252), a foreign banking organization's combined U.S. assets are measured using figures reported on the FR Y-15 or the FR Y-7Q, while its U.S. non-branch assets are measured by the FR Y-7Q alone. Those two numbers function as tripwires: cross the thresholds and enhanced prudential standards — including resolution planning requirements — apply, along with the mandate to form a U.S. intermediate holding company. The FR Y-7Q carries items 6 and 7 in Part 1A that are threshold figures as much as report lines, according to reporting on the form's structure.
The reporting itself has tightened. Since the December 31, 2024 report date, every FR Y-7Q filer has had 70 calendar days to deliver the form to its Reserve Bank — down from 90 days — under a revision the Fed Board approved in December 2023 and published at 88 FR 85886. The form's most recent burden estimate, from February 2025, counted 122 quarterly and 19 annual respondents. Its current OMB approval runs to March 31, 2028.
The Board describes the collection as consolidated regulatory capital information used to assess a foreign bank's ability to be a continuing source of strength to its U.S. operations and to gauge compliance with U.S. law. The authority is statutory: section 5(c) of the Bank Holding Company Act (12 U.S.C. 1844(c)) and sections 8(c) and 13 of the International Banking Act (12 U.S.C. 3105(c), 3106(c) and 3108).
In other words, the paperwork pipeline that feeds resolution planning has grown shorter and more binding. The feedback letters published Tuesday are the end product of that pipeline — the point where regulators stop gathering data and start telling banks what to do.
WHY TUESDAY'S RELEASE MATTERS
Resolution letters are not enforcement actions. They do not impose fines or force immediate changes. But they function as a public record of where examiners believe a bank's failure plan would come apart — whether a firm could separate its trading book from its deposit franchise, whether it has enough loss-absorbing capital parked in the right legal entities, whether its derivatives portfolio could be transferred without triggering a market freeze.
Those questions are not academic. When Silicon Valley Bank collapsed in March 2023, the speed of its failure outpaced the standard playbook, and depositors ran before any resolution plan could be executed. The episode gave regulators fresh ammunition to demand more credible wind-down strategies from the largest institutions.
The Fed's release does not say whether any of the 15 plans drew a joint finding of deficiency — the formal label that triggers a resubmission deadline and, in theory, the possibility of tougher capital or liquidity requirements. It also does not name the agencies that signed the letters alongside the Fed, though resolution planning for the largest firms has historically involved the Federal Deposit Insurance Corporation.
What is known is the count: 15 letters, published, with no summary of their contents attached.
For the banks, the letters set the next round of work. For everyone else, the release is a rare window into a supervisory process that normally runs behind closed doors — even if the window is, for now, mostly opaque.
Our Take
Here is the tell: the Fed published the letters and told the public almost nothing about them. Fifteen banks got their marching orders, and the announcement is one sentence long. If the resolution planning regime is supposed to protect taxpayers from another bailout, Americans deserve to know which institutions failed to convince their examiners — and which ones passed.
This is the administrative state in its purest form. A statute passed by Congress, a regulation written by unelected staff, a reporting deadline shortened from 90 days to 70, a form that decides whether a foreign bank must set up a U.S. holding company — and then a public release that says only that letters exist. The paperwork burden estimate counted 141 respondents. The public gets a headline.
Worse, the whole framework assumes the 2008 architecture still fits a banking system that has changed shape since. Regional banks failed in 2023 without being resolution-planning firms at all. Meanwhile, the biggest institutions keep filing plans, keep getting letters, and keep operating. If the process worked, we would not have needed a backstop for uninsured depositors at Silicon Valley Bank or Signature. The living wills were on file. The run came anyway.
Patriots should demand the letters themselves — the findings, the deadlines, the names. Sunlight is the only disinfectant that has ever worked on the banking cartel. If a bank cannot survive without a taxpayer backstop, the public has a right to see the document that says so. Fifteen letters are sitting in a drawer. Ask why nobody in Washington wants you to read them.
